Medicaid Work Requirements for Caregivers: What Counts and How to Prove Your Hours (2027)
From January 1, 2027, many Medicaid adults 19 to 64 must show 80 hours a month of work. Paid caregiving counts. Exemptions, proof and a free hours letter template.
By Caregiver Scheduling Team ·
Short answer. Starting no later than January 1, 2027, adults 19 to 64 who get Medicaid through the ACA expansion must show 80 hours a month of work, school, a work program or community service, unless they are exempt (CMS-2454-IFC). Paid caregiving hours are work. Many family caregivers are exempt.
General information, not legal advice. Rules change and depend on your facts. Confirm with the official source linked in each section or your state Medicaid agency before acting.
Your state runs this. States may start earlier than January 1, 2027 and decide how you report. Check your state Medicaid agency’s website for forms and dates.
Who has to meet the requirement?
Adults 19 to 64 in the Medicaid expansion group. People 65 and older, and people on Medicaid because of disability or long-term care, are generally not in this group (CMS-2454-IFC). Most home care clients are not affected. Working-age caregivers on Medicaid may be.
Does my caregiving job count?
Yes. Hours you are paid to work count toward the 80, including paid hours caring for a family member through an agency or a Medicaid program. The rule also allows income-based compliance, measured against 80 hours at the federal minimum wage. Check how your state applies it.
Who is exempt?
Exemptions in the law and interim rule include (CMS-2454-IFC):
- Parents, guardians, caretaker relatives and family caregivers of a child 13 or younger or of a person with a disability
- People who are medically frail
- Pregnant and postpartum people
- People meeting SNAP or TANF work rules
- Others listed by the law, such as some veterans and tribal members
An exemption usually still has to be reported or verified. Don’t assume the state knows.
How do I prove my hours?
- Keep every pay stub.
- Your caregiver app’s hours history is a record of visits worked.
- Ask your agency for an hours verification letter (template below) if the state asks for proof.
- Answer every state notice by the deadline. Expansion adults also renew every six months from 2027.
Hours verification letter (template for agencies)
[Agency letterhead]
[Date]
To: [State Medicaid agency]
This letter confirms that [Caregiver full name], date of birth [DOB], has been employed by [Agency legal name] as a [job title] since [hire date].
Hours paid by month: [Month YYYY]: [hours] [Month YYYY]: [hours] [Month YYYY]: [hours]
These hours are taken from our payroll records. Contact [name, title] at [phone] or [email] to verify.
[Signature] [Name, title]
Only state hours from payroll. Don’t estimate or include unpaid time.
What should agencies do now?
- Add a short notice to caregiver onboarding and paystubs in December.
- Flag caregivers trending under 80 paid hours a month, if they’ve told you they rely on Medicaid. Don’t ask about health coverage you don’t need to know.
- Decide who signs verification letters, and turn them around in two business days.
- Read the client-side changes in OBBBA for home care agencies.
FAQ
I care for my mom and I’m not paid. Do I have to work 80 hours? If she has a disability, you may qualify for the family caregiver exemption. Ask your state how to claim it.
I’m 66. Does this apply? No. It applies to ages 19 to 64.
Does my client lose home care if I lose Medicaid? No. This is about your own coverage, not your client’s.
Change log
- 2026-11-06 Published, from the primary sources listed in the frontmatter. State implementation dates are moving; we re-check monthly through March 2027.
Living page. Last reviewed November 6, 2026.